PCIT Cannot Initiate Section 263 Proceedings if AO Didn't Tax Cash Withdrawals in "Reason to Believe.

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....Validity of Revision u/s 263 - PCIT was of the view that the cash withdrawn was utilised to purchase inventory - if the AO did not bring to tax the amount which was adverted to in the “reason to believe” framed in the first instance, then the PCIT could not have triggered proceedings for cash withdrawals u/s 263 of the Act. - HC....